TechNet Submits Comments to Federal Trade Commission on Negative Option Rulemaking

Washington, D.C. - TechNet, the national, bipartisan network of tech CEOs and senior executives, today submitted comments to the Federal Trade Commission in response to its Advance Notice of Proposed Rulemaking (ANPRM) on proposed changes to the Rule Concerning the Use of Prenotification Negative Option Plans. The comments highlight that existing enforcement tools already provide strong consumer protections and urge the Commission to avoid duplicative or overly prescriptive requirements that could hinder innovation and degrade user experience.

"Subscription services offered by TechNet's members provide significant benefits to consumers and the broader economy," said TechNet President and CEO Linda Moore. "Any regulatory framework in this area must protect consumers from genuinely deceptive or unfair practices while preserving companies' ability to offer pro-consumer, subscription-based business models."

TechNet's highlights and asks include:

• The Commission's existing enforcement tools protect consumers
• The final rule should not require a separate "double opt-in" consent mechanism
• Cancellation requirements must be simple, accessible, and technically feasible, without prescriptive click-counting
• The rule should expressly permit "save offers"
• The rule's scope should be appropriately tailored, with a clear business-to-business exemption
• The rule should not impose additional requirements on free trial conversions

Read the full comment here.